RAMALINGAM & CO. vs THE STATE OF MADRAS

The Supreme Court ruled that under the Madras General Sales Tax Act, 1939, the property in goods sold under C.I.F. contracts does not pass within the province of Madras when the payment is made through a foreign bank. The Court held that the price for the goods was not received in Madras, and thus, the sale transactions were exempt from sales tax. The assessment by the Commercial Tax officer was deemed ultra vires as the export sales were outside the provisions of the Act.